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Last Day to Comment on Immunization Registry

Please comment today.

The New Hampshire Department of Health and Human Services is proposing a new rule that aligns with recommendations by the Federal Center for Disease Control to create a new database that would track you and your children’s personal medical information. The proposed rule would require medical providers submit the names, immunization status and over 75 other data points of children and other persons immunized in the state of New Hampshire. Today is the last day to offer comments on the proposed rule.

This information would be collected and stored unless a patient or their parent specifically opts out. There are over 75 elements that would be tracked, including a person’s financial status, living arrangements, ethnicity, race, class, language, “observation identifiers,” and reasons for refusing a particular substance.

Under the proposed rules, the registry will collect and store the data and provide access to the information to any person or agency authorized by the state who is concerned with the immunization or health-care screening of children. While the registry is required to keep these immunization records confidential, one of the central purposes for creating the statewide immunization registry is to provide the immunization status of children available to all authorized users, including local health districts, health-care providers, schools, and local social services district responsible for the care and custody of the children.

HSLDA is concerned that this database could result in significant privacy violations. Parents, not the government should be managing a child’s medical information and not through a statewide database.

Even if such a program were viable, at the very least it should be voluntary and operate as an “opt-in” program where people have to affirmatively give their permission for information to be stored, rather than an “opt-out” where a person must navigate a cumbersome process with the Department of Health and Human Services.

Action Requested

The proposed rules are open for public comment until the end of today. You may contact Michael Holt at the DHHS and give him the following message in your own words or provide other commentary and documents on the proposed rules:

“I oppose proposed rule He-P 307 that would create a statewide immunization registry for all children. Keeping records of personal medical information by the state is an unwarranted invasion of personal and family privacy, and private medical providers already maintain records on patients. Even if such a program were created, at the very least it should be ‘opt-in’ where individuals affirmatively grant permission for their data to be collected rather than an onerous opt-out as proposed under the rules.”

Background

Many parents are concerned about the medical risks of vaccinations. Parents, not the government, should have the right to make medical decisions, such as vaccinating their children. Parents should also have the ability to choose whether or not to place their children’s immunization history on an immunization registry. Making it harder to opt out of placing sensitive medical information on a registry restricts a parent’s right to monitor their children’s medical history. If this rule passes, many parents may become unaware that they can opt of sharing their children’s immunization history.

Thank you for all your work in defending parental freedom!

Live Free or Die!

Michael P. Donnelly, Esq.
HSLDA Staff Attorney

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